Short answer. No to grandparents, and generally no to cousins. Article 972 says the right of representation operates in the direct descending line but never in the ascending line, so a grandparent never represents. In the collateral line it works only for the children of brothers or sisters — nephews and nieces — not cousins.
What the law says
The right of representation takes place in the direct descending line, but never in the ascending. In the collateral line, it takes place only in favor of the children of brothers or sisters
Civil Code, Article 972 — Where Representation Operates. Read the full provision →
Never in the ascending line
Representation is the rule that lets a person step into the place of a nearer relative who cannot or does not inherit, taking the share that relative would have received. Article 972 fixes where it can operate. First: The right of representation takes place in the direct descending line, but never in the ascending. The direct descending line runs downward — children, grandchildren, great-grandchildren. The ascending line runs upward — parents, grandparents. So a grandparent can never inherit by representing a deceased child. Ascendants inherit in their own right when they are called to the succession, but they never take a share by stepping into a descendant's shoes.
In the collateral line, only nephews and nieces
The article then addresses relatives who are not in your direct line at all — the collateral line, which includes brothers, sisters, and their descendants. Here representation is tightly limited: In the collateral line, it takes place only in favor of the children of brothers or sisters, whether they be of the full or half blood. The children of your brothers and sisters are your nephews and nieces. They, and only they, may represent a deceased brother or sister. The half-blood is not excluded — a half-sibling's children represent just as full-blood ones do.
Where cousins stand
Cousins are the children of your aunts and uncles — collateral relatives, but not the children of your own brothers or sisters. So the collateral-line representation in this article does not extend to them. A cousin cannot represent a more distant relative to reach into your estate. Cousins may still inherit in the ordinary order of intestate succession when closer relatives are absent, but that is inheritance in their own right, according to their degree of relationship, not by the right of representation this article governs.
Why the line matters
The practical lesson is that representation is a narrow, deliberately bounded device. It pulls grandchildren up to take a predeceased child's share, and it lets nephews and nieces take a predeceased sibling's share, but it stops there. It does not run upward to benefit grandparents, and it does not run outward to cousins. Knowing which line a relative occupies — descending, ascending, or collateral — is what tells you whether representation can apply at all, before any question of how the shares are divided is even reached.
Cases citing this provision
These Supreme Court decisions cite the provision above. We list them so you can read them yourself; the summaries of what each decided are not ours to give.
- Martin Roberto G. Tirol vs. Sol Nolasco, G.R. No. 230103, August 27, 2020 — read the decision on LawPhil →
- Ma. Elena R. Divinagracia as Administratrix of the Estate of the Late Santiago C. Divinagracia vs Coronacion Parilla, et al, G.R. No. 196750, March 11, 2015 — read the decision on LawPhil →
- Estate of Tarcila vda. de Villegas vs. Jesus R. Gaboya, et al, G.R. No. 143006, July 14, 2006 — read the decision on LawPhil →
- In the matter of the intestate etc. vs. Heirs of Marciana Rustia Vda. De Damian, et al, G.R. No. 155733, January 27, 2006 — read the decision on LawPhil →